Flawed Solvency II risk margin is hurting consumers

Analysis by Willis Towers Watson finds the current formula is causing higher premium rates, reduced competition and poor value for consumers

LONDON, Thursday 16 March, 2017 — Willis Towers Watson has responded to a European Insurance and Occupational Pensions Authority (EIOPA) Discussion Paper on the upcoming review of Solvency II, where it has identified significant flaws in Willis-Towers-Watsonthe formula used to calculate the risk margin and recommended a fundamental review of its methodology and calibration.
Kamran Foroughi, Director at Willis Towers Watson, said: “We believe the high level of risk margin currently attached to long-term insurance products is resulting in higher premium rates and reduced competition, leading to worse value for consumers.”
Willis Towers Watson’s submission notes that the risk margin has become a much more material component of insurers’ balance sheets, leading to a number of challenges and changes in business practice, including:
• Asset Liability Matching. Insurers’ ALM challenges related to risk margin have been exacerbated by falling interest rates.
• Risk transfer. The bigger the risk margin relative to the rest of the technical provisions, the more insurers are incentivised to offload risk to reduce the risk margin.
This can be done via reinsurance to a company outside the EU which is not bound by Solvency II rules.
• Longevity reinsurance. We believe that the growth in the longevity reinsurance market has been caused primarily because the Solvency II risk margin is materially too large for relevant primary insurance business (mainly immediate annuities).
The consultancy’s submission, principally focused on the risk margin, recommends an independent review of the purpose of the risk margin and what an appropriate methodology and calibration should be.

The Solvency II Draft Directive was published in July 2007 and defined the risk margin to be part of the technical provisions and calibrated as a 6% per annum capital charge on non-hedgeable risks,” said Kamran Foroughi. “Throughout the rest of the Solvency II project up to adoption on 1 January 2016, there seems to have been no mechanism available to revisit this definition.”
Kamran Foroughi said: “After a fundamental review to confirm the broad model for the risk margin, stress and scenario testing should then be used to determine whether it should also change in different markets. If a risk margin model were to be permitted that varies with market movements, we would advocate an anti-cyclical approach as opposed to the current approach which we believe ends up being dangerously pro-cyclical.”

ABOUT WILLIS TOWERS WATSON
Willis Towers Watson (NASDAQ: WLTW) is a leading global advisory, broking and solutions company that helps clients around the world turn risk into a path for growth. With roots dating to 1828, Willis Towers Watson has 40,000 employees serving in more than 140 countries. We design and deliver solutions that manage risk, optimise benefits, cultivate talent, and expand the power of capital to protect and strengthen institutions and individuals. Our unique perspective allows us to see the critical intersections between talent, assets and ideas — the dynamic formula that drives business performance. Together, we unlock potential. Learn more at willistowerswatson.com.

MEDIA CONTACTS
Andrew Collis: +44 7932 725 267 | andrew@acolliscommunications.com

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